Monitoring Reviews, Common Findings and How To Avoid Them June 16, 2010
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Transcript of Monitoring Reviews, Common Findings and How To Avoid Them June 16, 2010
U.S. DEPARTMENT OF LABOREMPLOYMENT AND TRAINING ADMINISTRATION
ARRA GREEN JOB AND HEALTH CARE / EMERGING INDUSTRIES NEW GRANTEE POST AWARD FORUM
JUNE 15-16, 2010 | SAN FRANCISCO, CA
Monitoring Reviews, Common Findings and How To Avoid Them
June 16, 2010
Monitoring Reviews, Common Findings and How To Monitoring Reviews, Common Findings and How To Avoid ThemAvoid Them
What would you like to learn more about in today’s session?
COMMON FINDINGS & HOW TO AVOID THEMCOMMON FINDINGS & HOW TO AVOID THEM
Monitoring Overview Common Findings Tips for Avoiding Findings
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Purpose of MonitoringPurpose of Monitoring
Ensure that the Department of Labor grant funded program is aligned with: Statute/Regulations/Grant terms & conditions Federal financial and administrative requirements
including cost principles Grant Solicitation for Grant Application
Identify promising practices that can be shared Identify technical assistance needs
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Monitoring Methods Monitoring Methods
Types of Monitoring: Quarterly Performance Reviews Desk Monitoring Reviews On-Site Reviews
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM On-Site Reviews: BasicsOn-Site Reviews: Basics
Who conducts On-Site Reviews? FPO (additional ETA Staff)
When is the review conducted? Usually midpoint during your grant period of
performance What is the duration of the review?
Usually 2-3 days Notification of Review:
Letter confirming scheduled date of review and Core Monitoring Guide/Review Planning Tool mailed to Grant Recipient
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM On-Site Reviews: ToolsOn-Site Reviews: Tools
DOL ETA uniform guide for monitoring Five Core Activities
Design and governance Program / Grant Management Systems Financial Management Systems Service/product Delivery Performance Accountability
Core Monitoring Guide
April 2005
UNITED STATES DEPARTMENT OF LABOREMPLOYMENT AND TRAINING ADMINISTRATION
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM On-Site Reviews: Tools On-Site Reviews: Tools
REVIEW PLANNING TOOL U.S. DOL ETA Core Monitoring Review Guide
Grantee: Review
Date:
FPO:
Checked items indicate the activities/objectives that will be included in the monitoring review. To help plan the review, please fill in the names and titles of staff responsible for each activity/objective. Please refer to the Core Monitoring Guide for the detailed description of each core activity and objective. H
REVIEW ACTIVIT IES & OBJ ECTIVES
DOCUMENTS TO MAK E AVAILABLE FOR REVIEW
INTERVIEW NAME & T ITLE
CORE ACTIVITY 1: DESIGN AND GOVERNANCE—2 Hours
x 1.1 Strategic Planning Grantee organization’s vision, mission, strategy, and action planning documents
Labor Market Information (LMI ) used by the grantee organization to identify its area’s high-growth businesses and industries, their workforce needs, and the need for certain skills and competencies.
Grantee leadership/management staff
Primary staff responsible for LMI analysis
Business, industry and employer partners
x 1.2 Service Design Resource mapping tools Customer satisfaction surveys
Grantee management; staff responsible for providing business and job seeker services
x 1.3 Program I ntegration Policies, memoranda or documentation of program
integration
Appropriate staff Local Workforce
Investment Board, One-stop or other workforce investment partners as appropriate
CORE ACTIVITY 2: PROGRAM AND GRANT MANAGEMENT SYSTEMS Estimated Time Needed—3 hours
2.1 Administrative Controls
Policies and Procedures for core management functions and program operations
Monitoring tools and procedures and documentation of monitoring
Record retention and access policy
Primary staff responsible for development and issuance of policy, monitoring, and record retention
2.2 Personnel Personnel policy, including hiring process and procedures
Grantee organizational chart Project organizational chart
Staff responsible for personnel and human resources; other staff as appropriate
2.3 Civil Rights Grievance/complaint resolution and non-discrimination policies and procedures
Equal Opportunity officer and/or staff assigned responsibility for ensuring organization’s compliance with the EO laws
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM On-Site Reviews: Process/Report On-Site Reviews: Process/Report
Exit Conference Preliminary findings and observations
Written Report Findings and required corrective actions Opportunities for improvement Positive observations
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM On-Site Reviews: DefinitionsOn-Site Reviews: Definitions
Definition A finding is any “violation of”
Law Regulations Grant agreement SGA requirement
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Common FindingsCommon Findings
Changes were made to the Statement of Work without Grant Officer approval Change in scope or objective Adding/deleting program component Adding/deleting partner Changing target group
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Common FindingsCommon Findings
The Equal Opportunity (EO) requirements are not being fully implemented: The EO notice does not contain the required
wording 29 CFR 37.30 and/or; The EO notice is not posted or provided to
participants and made a part of their file and/or; Program brochures/outreach materials do not
contain the required wording 29 CFR 37.34
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Common FindingsCommon Findings
Grant funds were used to purchase equipment without Grant Officer approval Unit cost of $5000 and useful life of one year Prior approval required even if in included in the grant
budget This requirement also applies to subrecipients
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Common FindingsCommon Findings
The Grant Recipient realigned the budget without prior Grant Officer approval Exceeded the 20% line item flexibility requirement Made any changes to Personnel, Fringe or Indirect
Cost line items
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Common FindingsCommon Findings
Subrecipients are not monitored Every program, project, subaward, function and
activity must be monitored Need monitoring process, schedule, documentation
and corrective action process
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Common FindingsCommon Findings
Project significantly behind schedule in implementing grant activities
- Slow start-upLow expenditures/drawdowns
- Grant recipients must immediately notify DOL of developments which have significant impact on grant activities
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Common FindingsCommon Findings
Procurement files do not contain required support documentation
- Basis for contractor selection
- Justification of lack of competition
- Basis for award cost or price
COMMON FINDINGS & HOW TO AVOID THEM COMMON FINDINGS & HOW TO AVOID THEM Useful TipsUseful Tips
Knowledge of Requirements Ensure Core Monitoring Guide/Review
Planning Tool are shared with appropriate staff early on
Attend Training Implement the Common Findings Hand-out Ask Questions (contact your FPO)